Much of our coverage has been critical of the FDA, and its actions become less explicable every day. It is now five weeks since the “Import Alert” was issued and almost eight weeks since anyone is known to have gotten sick. It is almost a month since FDA and CDC inspectors visited the farm and left with their samples. Yet the Import Alert still stands.

It is certainly a shame and probably a sin that in a world where people are rioting for food, the FDA has scared the world so much that perfectly good cantaloupes are rotting because everyone is afraid to buy them and eat them.

The Honduran harvest season is now over. If the FDA doesn’t act soon, this company and country will be denied a chance to clear its name this season. Instead, the situation will drag into next season — if they can even get financing to plant crops for the US.

The best understanding of what is going on is that the FDA made a mistake, is embarrassed and, since it is institutionally incapable of admitting error, it needed to go down to Honduras, find a “problem” and get Agropecuria Montelibano to agree to fix this problem so FDA could announce that “corrective action” had been taken. Then it would lift the Import Alert.

Alas, FDA found nothing seriously wrong in Honduras. Thus it cannot announce corrective action has been taken. As a result, the Import Alert still stands.

Think about how bizarre this is. If FDA had gone down and found serious food safety violations, the company could take corrective action and the Import Alert would be lifted. Because the company has no serious food safety violations, there is nothing to correct and thus the Alert stands. It boggles the mind!

While the behavior of the FDA has been a focus of our coverage, we have been at pains to point out that whatever the flaws of the FDA approach, the industry still needs to focus on better understanding of food safety issues as well as efforts to reduce the food safety risk of our products.

The letter below is meant to dispel any perception that food safety is not a priority for the cantaloupe industry. To the contrary, the California Cantaloupe Industry has been at the forefront of commodity-specific food safety guidance on melons from field to fork for more than a decade. There is, in fact, a significant body of research available on the topic of cantaloupe food safety. We offer your readers today an overview of this research along with a summary of key findings. In addition, we provide comment on what could and should be done to prevent future outbreaks and unnecessarily broad and punitive market withdrawals.

The most important point we want to raise is that, although California cantaloupes have never been associated with an outbreak of foodborne illness, our industry does not take this issue lightly for two important reasons. First, our customers and the consumers who eat and enjoy fresh cantaloupes deserve to be assured they are buying a safe and nutritious product. Second, as we’ve seen in the past, concern about outbreaks associated with cantaloupe produced anywhere can have a significant economic impact on all producers. This is why the California cantaloupe industry took action nearly a decade ago.

Beginning in 1999, the California cantaloupe industry engaged University of California scientist Dr. Trevor Suslow to proactively initiate an ambitious food safety research program. This program examined all aspects of California cantaloupe production for potential contamination risks, established best practices and recommended new technologies and production methods.

Dr. Suslow’s research results showed that the hot and arid climatic conditions in the Central Valley and southern desert regions, where most of the state’s fresh melons are grown, make for a very unfavorable environment for the survival of high levels of foodborne pathogens. Further the irrigation practices of our industry, which strive to keep moisture away from the fruit, also assist in minimizing the risk of contamination and growth of pathogens on cantaloupes in the field. In fact, during Dr. Suslow’s extensive research project, thousands of cantaloupes were randomly selected and tested for the presence of salmonella. The pathogen was never found on any of these California cantaloupes.

Still, the industry pressed on in its efforts to address food safety. Food safety became the number one issue of concern for the California Cantaloupe Advisory Board, the state marketing order representing California cantaloupes. Requirements were added to the marketing order for government certified mandatory traceback on all cantaloupes shipped. This was the first program of its type in the United States fresh fruit industry. New best practices designed to prevent potential contamination in the field and packing houses were put in place.

In 2004, the cantaloupe industry was the first commodity to complete the FDA recommended Commodity Specific Guidance Document for Melons document,which encompasses all melons produced in the United States. Our work continues today with two new research projects involving food safety slated for the coming year. Please note that all of the California cantaloupe industry-sponsored research is available through the University of California, Davis, and is posted on the California Melon Research Board website at www.cmrb.org This information includes tutorials for growers, packers and consumers.

Clearly, this cannot be the stopping point and we find ourselves in agreement with the Pundit in its assessment that more research is needed. Once again, we turned to our respected food safety scientist Dr. Suslow for his thoughts, which he will share with you in a separate letter. From the California cantaloupe industry’s perspective, we hope that research such as what is suggested by Dr. Suslow can and will move forward working with organizations like the Center for Produce Safety, USDA and the FDA, in addition to our own industry’s funding mechanisms for research needs.

On a final note, we must emphasize the importance of consumer education. The primary cause whenever cantaloupes have been involved in a foodborne illness outbreak has been the transfer of pathogens from the outside rind to the internal flesh — usually occurring when melons are sliced. Dr. Suslow emphasizes that this is mostly problematic when the pathogens on the rind are present at a high enough level and/or the fruit is cut and then left to sit at room temperature for an extended period.

This being said, there are actions which can be taken by the consumer and foodservice operators to prevent outbreaks. As with any preparation involving fresh produce, knives, cutting boards and all utensils should be clean. Melons should be washed in cool running water and scrubbed with a clean brush. Cut fruit should be refrigerated and should be consumed as closely after cutting as possible.

These are simple steps and as part of its food safety education program, the California Cantaloupe Board has developed a web page with consumer-friendly messaging on cantaloupe food safety and handling. This web page, available at http://www.cmrb.org/tips/ can be linked to any website and should be added to the food safety section of all retail and grocery store websites to help spread this important message.

In addition, following the recent Honduran cantaloupe situation, Dr. Suslow developed a white paper with detailed information on methods for washing cantaloupe for those who are especially concerned about preventing illness http://postharvest.ucdavis.edu/datastorefiles/234-928.pdf. Suslow is quick to note that these methods are not really necessary, but for those who want to take extra precautions, this is the proper way to do it.

We hope the above information communicates adequately that concern about food safety is paramount for a large segment of the U.S. cantaloupe industry and that real and measurable action is being taken to ensure a safe product. And while the California cantaloupe industry takes responsibility for preventing outbreaks from occurring in our own fields and packinghouses, we are willing to share, discuss and work with other production areas to conduct the necessary research which will ensure outbreaks associated with cantaloupes are eliminated for us all.

— Stephen PatricioChairman, California Cantaloupe Advisory Board

— Stephen SmithChairman, California Melon Research Board

It was truly a pleasure to receive this letter, both because an industry so proactive on food safety is something to be celebrated and because Stephen Patricio is the gentleman responsible for the Pundit joining WGA.

We eagerly awaited the letter from Dr. Trevor Suslow, who we have mentioned many times in the Pundit and interviewed about food safety here.

We also included Dr. Suslow’s suggestions for consumers interested in cleaning their cantaloupes right here. Dr. Suslow’s letter arrived shortly after the above-mentioned letter:

It has been quite a year already.

A few individuals forwarded your recent entry, “Despite Flawed FDA, Cantaloupes are Challenged,” to ask me about the apparent lack of science behind efforts to reduce the chance of detectable contamination by Salmonella on cantaloupes and why honeydews grown in close regional proximity don’t appear to have the same issues.

At the same time, the California Melon Research Board and California Cantaloupe Advisory Board asked if I would send a short note to highlight the large body of melon food safety research supported by the California industry and federal level funding. I am happy to do this as I greatly appreciate and acknowledge the past research and outreach support provided by the California Melon Research Board and the California Cantaloupe Advisory Board, starting at a time when commodity group support for science-based GAP and GHP assessments was much less common.

From this springboard, we were successful in securing USDA CSREES funding for several multi-state efforts focused predominantly on cantaloupe. Researchers from UC Davis, University of Georgia, University of Florida, Texas A&M, Iowa State University, ARS scientists at the Western, Eastern, and Southern Research Centers, and collaborators in Mexico were supported by the multi-year grants.

Numerous cantaloupe-specific (with a bit of honeydew comparisons as well) journal publications came out of these findings and were presented in several industry workshops and three regional cantaloupe food safety seminars in California, Mexico, and Georgia, supported by USDA CSREES. A large collection of research papers contributed by other domestic and international research groups exists that encompass many aspects of cantaloupe preharvest, but especially postharvest, risk factors and mitigation practices or options.

A good deal of this research involves disinfection at shipping point and prior to foodservice or fresh-cut processing. The presentations from these seminars and a large bibliography of melon food safety research citations was available at http://www.ucfoodsafety.ucdavis.edu, but was removed about two years ago. I have committed to update these and make them available, within the next week, to the California Cantaloupe Advisory Board for posting on their website and available for linkage to other resource centers, such as the Center for Produce Safety.

To keep this note relatively brief, we know that Salmonella can survive on cantaloupe for an extended period and has the potential to multiply on the netted cantaloupe rind, under permissive distribution and storage conditions. External contamination may gain access to sub-rind tissues during immersion or flotation, if these practices are used and not well-managed. Internalization may also happen by growth of common surface molds that develop with handling and ripening. We also know that timely cooling and several treatments, such as effective chlorine brush-washing, heat, ozone, peracetic acid, essential oils, lactic acid, and others alone or sequentially will greatly reduce these risks.

Within this multi-year project, the greater challenges to surface disinfection of the netted cantaloupe as compared to smooth waxy honeydew were demonstrated. Much of the outcomes of this research was first communicated to the industry and made available to public health regulators in a lay-technical brochure and extension guidance paper:

• In 2003 — DANR # 8103. Key Points of Control and Management of Microbial Food Safety: Information for Producers, Handlers, and Processors of Melons;

• In 2004 — Minimizing the risk of foodborne illness associated with cantaloupe production and handling in California: Overview of Industry Practices and Risk Assessment. 24pp. In addition, two informational videos to encapsulate the research information into guidance overviews were produced;

That these research findings and outcomes are not more broadly recognized within the industry and among food safety experts providing input to the Pundit is a clear Call to Action for the food safety extension network. We need to do a better job of ensuring this information is disseminated and accessible beyond the immediate primary users and some of their customers.

Looking forward, even prior to the most recent outbreak and massive recall, it seemed prudent to evaluate the specificity and sensitivity of the newer rapid detection and recovery systems for Salmonella on cantaloupe in light of the CFIA and FDA surveillance-activated voluntary recalls of imported melons in 2006 and 2007. The two California Boards agreed to jointly support an effort toward these practical objectives in our lab this season as well as a baseline-setting survey of regional irrigation water for future guidance ‘metrics’.

From a more basic risk assessment need, the melon boards requested we conduct funded, exploratory research into the plausibility of preharvest internalization of bacteria into vines and fruit from irrigation or soil sources.

Beyond the research funded by the California and Arizona industry, through the Cantaloupe Advisory Board, the events surrounding the recent outbreak implicating cantaloupes seem to dictate that greater federal dollars or other sources of block funding in research and on-the-ground assessments need to be allocated to epidemiology and pathogen source tracking. A data-based linkage between quantitative levels of detectable pathogens and community-based illness is sorely needed to bring some sense and order to the consequences of our greatly increased ability to recovery pathogens, such as Salmonella, from the outer rind of cantaloupes at shipping point and beyond.

This is not at all a trivial undertaking, and I am not the one to do it. The right combination of expertise needs to be brought in with some practical input and adequate access provided by the industry. There are, naturally, other research knowledge gaps that need to be filled as well, but to be honest I think the simple things have been “beat to death” and the constant pursuit of esoteric vectors of pathogens may be diluting research resources to more probable sources.

However, a more direct numbers-association between pathogen presence and sporadic illness must be elucidated to strategically and intelligently move beyond the current food safety foundation. Given the appearance of disregard for the investment of resources devoted to systematic food safety programs, research investments should be carefully evaluated for the potential to compel adoption of practices that improve consumer protection and the sustainability of agricultural techniques.

In short, I hope and expect that those involved in research funding prioritization in the coming months and the food safety research community at large will spend less energy emphasizing the search for the “silver bullet” kill-step and more on resolving sources of contamination and the environmental biology of key pathogens in different regions.

Dr. Suslow has completed his updating of the bibliography of the food safety literature on cantaloupes and, along with the California Cantaloupe Advisory Board and the California Melon Research Board, has been kind enough to allow us to make a copy available here.

We appreciate both letters, and the Pundit is not foolish enough to parse scientific food safety issues with Dr. Suslow.

What we do know is this. We keep having food safety issues with cantaloupes. Dr. Suslow’s letter mentions the “…CFIA and FDA surveillance-activated voluntary recalls of imported melons in 2006 and 2007…” and now we have a situation in 2008.

It is simply imperative that we get to the bottom of the cause of these food safety issues or a whole commodity will be at risk.

How many recalls does a fresh-cut facility have to experience before its executives decide that it can survive without cantaloupe in its fruit salad?

Dr. Suslow’s efforts to help consumers looking for ways to wash cantaloupe so as to safeguard their health is certainly laudable. Unfortunately, despite almost every step in the distribution chain having food safety responsibilities, the current state of the law is that FDA will consider any salmonella found on a cantaloupe an adulterant.

There is no question that the cantaloupe industry is dedicated to advancing research — more so than many commodities.

Still, Dr. Suslow’s letter points out the clear limits to our knowledge. And it makes nine specific suggestions related to current and future research:

…evaluate the specificity and sensitivity of the newer rapid detection and recovery systems for Salmonella on cantaloupe…

…plausibility of preharvest internalization of bacteria into vines and fruit from irrigation or soil sources…..

…greater federal dollars or other sources of block funding in research and on-the-ground assessments need to be allocated to epidemiology and pathogen source tracking….

…A data-based linkage between quantitative levels of detectable pathogens and community-based illness is sorely needed to bring some sense and order to the consequences of our greatly increased ability to recovery pathogens, such as Salmonella from the outer rind of cantaloupes at shipping point and beyond. …

…the constant pursuit of esoteric vectors of pathogens may be diluting research resources to more probable sources….

… a more direct numbers-association between pathogen presence and sporadic illness must be elucidated to strategically and intelligently move beyond the current food safety foundation….

…research investments should be carefully evaluated for the potential to compel adoption of practices that improve consumer protection and the sustainability of agricultural techniques…

…spend less energy emphasizing the search for the “silver bullet” kill-step and more on resolving sources of contamination and the environmental biology of key pathogens in different regions….

Many food safety experts believe that #3 — exploring the “….plausibility of preharvest internalization of bacteria into vines and fruit from irrigation or soil sources…” — is absolutely crucial. However, all of Dr. Suslow’s points are well taken.

The cantaloupe industry has been sponsoring food safety research since long before most commodities. They have made real progress in advancing our understanding in this area. There is, however, more work to be done.

Publicity affecting cantaloupes impacts the whole industry, so it behooves the trade, in general, to support cantaloupe growers in their effort to better understand the issues. Perhaps some of the research funds that the Center for Produce Safety will invest could go to this effort.

We also wonder if some kind of national marketing order, similar to the National Watermelon Promotion Board, whose executives we interviewed here, couldn’t be set up so that imported cantaloupe producers would also be contributing to fund food safety research.

In any case, we thank Stephen Patricio, Chairman of the California Cantaloupe Advisory Board and Stephen Smith, Chairman of the California Melon Research Board, for reaffirming the trade’s deep commitment to food safety, and we thank Dr. Trevor Sulow of UC Davis for providing a roadmap on how, as an industry, we might get to a safer future.